On June 11, CVSA sent a letter to PHMSA requesting a letter of interpretation clarifying whether manifold cylinders with individual closures should be treated as bulk or non-bulk packages for the purposes of applying the hazardous materials marking requirements found in Part 172.
Letters, Petitions and Comments
CVSA Sends Letter of Support for U.S. House BUILD America 250 Act
On May 19, CVSA sent a letter to the leadership of the U.S. House of Representitives Transportation and Infrastructure Committee expressing support for the Building Unrivaled Infrastructure and Long-term Development for America’s 250th Act (BUILD America 250 Act).
CVSA Submits Comment Regarding Grote RCW Lighting Exemption
On May 7, CVSA submitted comments on the application for exemption from Grote Industries LLC (Grote) that would allow motor carriers to operate CMVs equipped with auxiliary rear or side lamps that flash or strobe when controlled by Grote’s Rear-End Collision Warning (RCW) system.
CVSA Submits Comments on Transporting Hazardous Materials Using Heavy-Duty EVs
On April 30, CVSA submitted comments responding to PHMSA’s request for feedback on the safety risks, operational challenges and regulatory considerations associated with transporting hazardous materials using heavy-duty electric vehicles (EV) compared to internal combustion engine vehicles (i.e., gas or diesel).
CVSA Petitions FMCSA to Revise the Adjudicated Citations Policy
On April 16, CVSA petitioned FMCSA to revise the adjudicated citations policy to allow states to deny a request for data review when it is determined that masking of an underlying unsafe driving violation has occurred, which is prohibited under § 384.226.
CVSA Petitions FMCSA to Amend § 393.87
On March 25, CVSA petitioned FMCSA to amend Title 49 Code of Federal Regulations (CFR) § 393.87, Warning flags on projecting loads, to add language excluding rear mounted forklifts from the requirement when the item is secured to the rear of the transport vehicle and is connected to the transport vehicle with an electrical connection to activate brake, tail, hazard and turn signal lamps.
CVSA Sends Letter Seeking Clarification on the Applicability of HMSP
On March 20, CVSA sent a letter to FMCSA requesting that the agency provide written clarification regarding the applicability of hazardous materials safety permits (HMSP) in Part 385 Subpart E.
CVSA Submits Comments to FMCSA’s Request for Comments on the Extension of NRII Waiver
On March 9, CVSA submitted comments in response to FMCSA’s request for feedback on CVSA’s request that the agency allow motor carriers and drivers to rely on a paper copy of the medical examiner’s certificate as proof of the driver’s medical certification until the Medical Examiner’s Certification Integration (NRII) final rule is fully implemented.
CVSA Submits Comments to FMCSA’s NPRM on Emergency Exemptions
On March 6, CVSA submitted comments on FMCSA’s NPRM seeking stakeholder input on the agency’s response to petitions for reconsideration regarding the length of the emergency relief automatically triggered subsequent to a regional declaration of emergency by a governor of a state, their authorized representative or FMCSA.
CVSA Submits Comments to PHMSA on the Safe Transportation of Hazardous Materials Using Highly Automated Transportation Systems ANPRM
On March 4, CVSA submitted comments on the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) advance notice of proposed rulemaking (ANPRM) for potential revisions to the Hazardous Materials Regulations (HMR) to facilitate the safe transportation of hazardous materials using highly automated transportation systems.
CVSA Submits Comments on ATA’s Minimum Age for Drivers Exemption Application
On Feb. 27, CVSA submitted comments on the American Trucking Associations’ (ATA) application for a five-year exemption to allow motor carriers that previously participated in FMCSA’s Safe Driver Apprenticeship Pilot program to continue onboarding and training drivers under the age of 21.
CVSA’s Requests Extension for Comment Period on Grote RCW Exemption Application
On Feb. 24, CVSA requested an exemption on the application from Grote for exemption from the requirement that exterior lighting devices on CMVs be steady burning.
CVSA and CVBMC Submit Comments on Applying the FMVSS to ADS Vehicles
On Feb. 13, CVSA, on behalf of the Commercial Vehicle Brake Manufacturers Council (CVBMC), submitted comments in response to NHTSA’s request for stakeholder feedback on its research project evaluating the FMVSS to determine how they apply to innovative vehicle designs, particularly those incorporating ADS, as well as potential challenges these vehicles may face in demonstrating conformance.
CVSA Sends Letter to FMCSA on Enforcement of the ‘K’ Restriction for CMV Drivers
On Feb. 3, CVSA sent a letter to FMCSA requesting enforcement guidance regarding the definition of “interstate commerce” within the context of the intrastate license (K) restriction requirements, which limit a CMV driver to intrastate-only operations.